The Michigan Corporate Income Tax (CIT) replaced the Michigan Business Tax in January 2012. While it is arguably a more business-friendly tax, it still includes a number of complex topics. Join us for this half-day seminar to better understand the unitary filing and apportionment issues that arise in complying with the Michigan corporate income tax. This half-day seminar will be a “deep dive” into these issues with examples.

What Will Be Covered:

The unitary business group and issues arising from unitary filing

Apportionment issues under the CIT, including the apportionment of sales of tangible personal property, revenues from services and other "sales"

Apportionment issues for unitary filers

Most recent legislative changes to the tax and administrative interpretations issues and how they impact tax return preparation, including the most troublesome calculations

Agenda:

Unitary Business Groups

Identifying Members of a Unitary Business Group

Control Test and Attribution Rules

Relationship Test

Unitary Group Structures

Unitary Pass-Through Entities

Beginning and Ending of Unity

Taking Entities into and out of the Unitary Business Group

Foreign Corporations and 80/20 Companies

Foreign Dividends

Elimination of Intercompany Transactions

Denial of Deductions From Nonunitary Affiliates

Apportionment Issues

The Apportionable Tax Base

What is a "Sale" Included in the Sales Factor

Sourcing of Receipts from Tangibles

Sourcing Receipts from Services

Sourcing Receipts from Intangibles

How to document where a benefit is received

Accounting for income from Flow-Through Entities

Apportionment Challenges

How to prove distortion or misattribution of income

Challenges to Single Sales Factor Apportionment

When and How to Request Alternative Apportionment

Recent Developments

Legislative Changes

Guidance and Proposed Guidance from the Department of Treasury

Forms and Tax Calculation Issues Wrap-up

Certification:

This seminar qualifies as three (3) credits toward the Basic or Advanced Tax Policy and Finance Compliance Certification Programs. This seminar also qualifies as three (3) credits under the guidelines of the Michigan State Board of Accountancy.